Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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A public listed company (RHFL) was involved in siphoning off funds by structuring them as 'loans' to creditworthy conduit borrowers, resulting in disproportionate lending and moving funds to non-descript, financially weak privately held companies connected with the Reliance ADA group. Adequate disclosures were not made to public shareholders, violating securities laws. The fraud involved a complete breakdown of governance orchestrated by the promoter (Noticee No. 2 - Anil Ambani) and aided by key managerial personnel (KMPs). The KMPs (Noticees 3-5) played an active role, defying board directives and making false disclosures. Most borrower accounts turned NPAs, leading to RHFL defaulting on payments and resolution under RBI framework, severely impacting public shareholders. The order established a fraudulent scheme to siphon funds through sham 'loans' to conduit borrowers linked to Noticee No. 2. Directions were issued restraining Noticees from accessing securities market, associating with listed companies/intermediaries, and imposing penalties for violating securities laws and damaging market integrity.
A public listed company (RHFL) was involved in siphoning off funds by structuring them as 'loans' to creditworthy conduit borrowers, resulting in disproportionate lending and moving funds to non-descript, financially weak privately held companies connected with the Reliance ADA group. Adequate disclosures were not made to public shareholders, violating securities laws. The fraud involved a complete breakdown of governance orchestrated by the promoter (Noticee No. 2 - Anil Ambani) and aided by key managerial personnel (KMPs). The KMPs (Noticees 3-5) played an active role, defying board directives and making false disclosures. Most borrower accounts turned NPAs, leading to RHFL defaulting on payments and resolution under RBI framework, severely impacting public shareholders. The order established a fraudulent scheme to siphon funds through sham 'loans' to conduit borrowers linked to Noticee No. 2. Directions were issued restraining Noticees from accessing securities market, associating with listed companies/intermediaries, and imposing penalties for violating securities laws and damaging market integrity.
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